Justia Washington Supreme Court Opinion Summaries

Plaintiff Leo Macias worked as a tool keeper in a shipyard and his job required that he maintain respirators that other workers wore to filter out dangerous contaminants. Plaintiff and his wife Patricia brought this suit against the respirator manufacturers, alleging that cleaning and maintaining the respirators exposed Mr. Macias to asbestos, causing him to develop mesothelioma. The plaintiffs claimed that the manufacturers owed a duty to warn Mr. Macias of the danger that he could be exposed to harmful asbestos dust when he cleaned and maintained the respirators. The respirator manufacturers moved for summary judgment on the ground that as a matter of law they owed no duty to warn. The trial court denied the motion. The Court of Appeals reversed, holding that under Washington case law the defendants did not owe a duty to warn because they did not manufacture the asbestos-containing products that were the source of the asbestos to which Mr. Macias was exposed. Upon review, the Supreme Court reversed the Court of Appeals. In the two precedential cases, the Court held that generally a manufacturer does not have a duty to warn of the dangers inherent in a product that it does not manufacture, sell, or supply. However, "Simonetta" and "Braaten" did not control in this case because the duty at issue was to warn of the danger of asbestos exposure inherent in the use and maintenance of the defendant manufacturers’ own products- - the respirators. View "Macias v. Saberhagen Holdings, Inc." on Justia Law

David Ward and Michael Whittaker were commissioners for the Jefferson County Fire Protection No. 2 (the District). Two citizens of the District, Harry Goodrich and Linda Saunders (the petitioners), initiated a recall proceeding against Ward and Whittaker, alleging various counts of misfeasance. The issue before the Supreme Court was whether the recall petition should advance to the signature-gathering phase of the recall process. Upon review, the Supreme Court affirmed the trial court and held that one of the four charges against Ward and Whittaker may advance to the next phase of the recall process. View "In re Recall of Ward" on Justia Law

Rogelio and Elaine Ruvalcaba brought suit to condemn an easement across neighboring property held by individual landowners, referred to collectively as the "Day Group Petitioners." The Ruvalcabas argued that they were entitled to an easement because their property is landlocked and contended that there is an overriding public policy against rendering landlocked property useless. The Day Group Petitioners contended that the Ruvalcabas voluntarily landlocked their property through severance of the parcel and failed to bring a condemnation action for 35 years. The trial court granted summary judgment to the Day Group Petitioners and dismissed. The Court of Appeals reversed. Upon review, the Supreme Court reversed the Court of Appeals and affirmed the trial court’s order granting summary judgment to the Day Group Petitioners. View "Ruvalcaba v. Baek" on Justia Law

Petitioner Douglas Rose challenged his convictions for unlawful possession of a stolen access device and for unlawful possession of a controlled substance. The issue before the Supreme Court was whether the credit card Petitioner possessed was an "access device" under Washington law. Further, the Court was presented with the issue of whether Petitioner's arrest, which lead to the search of his bag and discovery of the evidence eventually presented against him, was supported by probable cause. Under the facts of this case, the Supreme Court concluded that the State did not meet its burden to show that the card in question was an "access device." The Court reversed on that issue, but affirmed Petitioner's arrest on all other grounds. View "Washington v. Rose" on Justia Law

Defendant-Appellant Jamar Meneese appealed his conviction for unlawfully carrying a dangerous weapon on school grounds and for possessing a controlled substance. He claimed the weapon, an air pistol, was seized in an unlawful search at school and should have been suppressed at trial. The question on appeal was whether the school search exception to the warrant requirement applied to the search conducted by the school resource officer (SRO). The parties disputed whether the SRO was acting as a school official or a law enforcement officer at the time of the search. Upon review, the Supreme Court found that the SRO is a fully commissioned, uniformed, law enforcement officer employed by the Bellevue Police Department. He arrested and handcuffed Defendant before searching his backpack. Moreover, after arresting Defendant, the focus of the investigation was no longer on informal school discipline (an underlying purpose behind the school search exception.) Accordingly, the Court concluded the school search exception did not apply, a warrant supported by probable cause was required, and the weapon should have been suppressed. View "Washington v. Meneese" on Justia Law

This case concerned the classification of workers as employees or independent contractors for purposes of the Washington Minimum Wage Act (MWA). A class of 320 former and current FedEx Ground Package System, Inc. (FedEx) delivery drivers (hereinafter Anfinson) filed suit seeking overtime wages under the MWA and reimbursement for uniform expenses under the industrial welfare act (IWA). The dispute with respect to both claims was whether the drivers were employees or independent contractors. The parties disagreed on the correct test to distinguish these categories under the MWA; FedEx argued that the common law right-to-control standard governs while Anfinson contended that the federal Fair Labor Standards Act of 1938 (FLSA) economic-dependence test controls. The trial court gave the jury a hybrid instruction, focusing the inquiry on FedEx's right to control in light of the economic-dependence factors. The jury determined that the drivers were independent contractors. Anfinson appealed, contending, among other things, that the jury instructions misinformed the jury about the standards for determining worker status and about the requirement that class status and evidence be "common to the class members." The Court of Appeals held that the jury instruction defining the standard for determining worker status was erroneous and prejudicial and reversed. The Court of Appeals further held that the jury instruction on the burden of proof was erroneous because it misled the jury and was prejudicial. Upon review, the Supreme Court affirmed the Court of Appeals in both respects. View "Anfinson v. FedEx Ground Package Sys., Inc." on Justia Law

William Adam Gray shot Vita M. Moimoi and Sanelive S. Hikila at close range. Moimoi suffered a serious leg wound and Hikila bled to death. Although Gray fled the scene, he was soon identified and charged with second degree felony murder, first degree assault, and unlawful possession of a firearm. Gray remained at large for almost two years before being arrested. Gray pled guilty to first degree manslaughter and second degree assault. At a sentencing hearing, the State requested restitution in an amount to be determined after the victim's assistance unit (VAU) had computed the appropriate amount. The court agreed, and Gray waived his right to be present at any future hearing. At issue in this case was whether RCW 9.94A.753(4) permitted a court to modify a restitution order more than 180 days after sentencing to include expenses that were incurred before the trial court issued its original restitution order. Upon review, the Supreme Court held that the plain language of RCW 9.94A.753(4) clearly authorizes courts to make such modifications. View "Washington v. Gray" on Justia Law

Leysa and Leah Sweany challenged the sufficiency of the evidence supporting their convictions for arson in the first degree. In 2009, a fire damaged their trailer. The State charged both with alternative means of committing arson in the first degree, relying on the means of causing "a fire or explosion which damages a dwelling," and on the means of causing "a fire or explosion on property valued at ten thousand dollars or more with intent to collect insurance proceeds." The Sweanys argued that the State failed to present sufficient evidence that the property on which they caused a fire was valued at $10,000 or more. Though the Supreme Court concluded that the Sweanys correctly argued that the relevant value was the fair market value of the property, the Court also concluded that sufficient evidence supported this element. Accordingly, the Court affirmed the Court of Appeals judgment upholding their convictions. View "Washington v. Sweany" on Justia Law

This case concerned the standard for assessing prejudice in a personal restraint petition alleging ineffective assistance of counsel. Petitioner Hoyt Crace was convicted of attempted second degree assault with a deadly weapon. This was his third strike offense, resulting in a life sentence without the possibility of early release. Petitioner brought this personal restraint petition asserting he received ineffective assistance of counsel when his trial counsel did not request an instruction on the lesser-included offense of unlawful display of a deadly weapon, a nonstrike offense. A divided Court of Appeals applied the analysis for an ineffective assistance of counsel claim set forth in "Strickland v. Washington," (466 U.S. 668 (1984)), concluding that a showing of prejudice under this analysis satisfied the “actual and substantial prejudice” showing required on collateral attack. Without the benefit of the Washington Supreme Court's decisions in "Washington v. Grier," (246 P.3d 1260 (2011)) and "Washington v. Breitung," (267 P.3d 1012 (2011)), the court then granted Petitioner's petition, holding that trial counsel’s performance was deficient and that counsel’s error prejudiced him. Upon review, the Supreme Court reversed the Court of Appeals, finding that the court correctly analyzed prejudice under the Strickland standard, Petitioner could not show prejudice arising from the omitted instruction. View "In re Pers. Restraint of Crace" on Justia Law

Petitioner Jennifer Leigh Rice, a former public school teacher, molested one of her 10-year-old students. Her conduct was found to be predatory as charged in a special allegation under RCW 9.94A.836. She also abducted the same 10-year-old boy and was convicted of kidnapping with special allegations under RCW 9.94A.835 and .837 for sexual motivation and for having a victim under age 15. The special allegations increased her sentence. Petitioner argued on appeal that her convictions should be overturned because the legislature made charging the above special allegations mandatory, in violation of the constitutional separation of powers doctrine. Further, Petitioner argued that .835 was unconstitutional because it requires a prosecuting attorney to file a special allegation whenever there is sufficient evidence to support the allegation and that .836 and .837 were unconstitutional because each requires a prosecuting attorney to file a special allegation whenever there is sufficient evidence to support the allegation and so long as the allegation will not interfere with obtaining a conviction. The Court of Appeals held that the charging statutes do not unduly limit prosecutorial discretion because even if a charging requirement is imposed, the prosecutor still must determine whether there is sufficient supporting evidence and whether the supplemental charge would interfere with obtaining a conviction. Upon review, the Supreme Court affirmed, but on grounds different than those by the appellate court. The Supreme Court found that the challenged statutes are directory rather than mandatory. "Although the statutes authorize special allegations and direct prosecuting attorneys to file them, the statutes do not attach any legal consequences to a prosecutor’s noncompliance, and the legislature elsewhere in the same chapter has acknowledged that prosecuting attorneys retain broad charging discretion notwithstanding statutory language directing them to file particular charges. . . .Our interpretation also rests on the fact that the challenged statutes would be unconstitutional if they were mandatory." The Court upheld the statutes in question and affirmed Petitioner's conviction and sentence. View "Washington v. Rice" on Justia Law